Privacy statement

Freestone observes the applicable GDPR Regulation and other privacy laws in all cases.

This means that in any case:

• We process your personal data according to the purpose for which it was provided; this privacy statement provides details about said objectives and the type of personal data.
• We restrict the processing of your personal data to the data that is required for the purpose to which it is being processed.
• We ask your explicit consent if that is needed for processing your personal data.
• We have taken technical and organisational measures to ensure that your personal data is secure.
• We do not forward personal data to third parties unless it is necessary for implementing the purposes for which it was provided.
• We are aware of your rights regarding your personal data, we wish to point them out to you and respect them.

IDENTITY OF THE PARTY RESPONSIBLE FOR PROCESSING THE PERSONAL DATA

Freestone nv (hereinafter referred to as ‘Freestone’), with registered office at B-1780 Wemmel, 10 De Hene, and registered in the Crossroads Bank for Enterprises (CBE) under number 0887.436.073, is the party responsible for processing your personal data. The party responsible for processing the personal data is the party that decides on the purpose and the means (i.e. what, how and why) of the data processing.

Freestone may be contacted by post, by phone at +32 2 453 95 50, by email at contact@freestone.be or via the contact form on its website www.freestone.be.

In relation to this privacy statement, besides reaching us as indicated above the following person may be contacted:

Mrs Ann Van den Wyngaert, at ann.vandenwyngaert@freestone.be or +32 475 72 22 43.

WHY FREESTONE NEEDS YOUR PERSONAL DATA

We process your personal data to ensure that we can offer our services in an efficient and professional way. We process your data to improve our service provision and enhance customer satisfaction.

If you are looking for a job, we will process your data to:

• help you find a suitable position
• keep you informed of new job vacancies by phone, email and/or mailings
• keep you informed about actions that have been taken and results in the context of applications
• pass your data to other companies, subject to your explicit consent
• take references, subject to your explicit consent
• be able to offer you high-quality services
• keep you informed through reports and presentations
• keep you informed of our training offer and practical information
• advise you about our services
• advise you about trends and developments
• request your feedback about our services and collaboration

If you seek to use our services as a client or as a participant in training courses, we will process your data to:

• be able to offer you high-quality services
• keep you informed through reports and presentations
• keep you informed of our training offer and practical information
• advise you about our services
• advise you about trends and developments
• request your feedback about our services and collaboration

Furthermore, we process data of potential clients and suppliers to be able to offer our services.

Certain data will be processed in the context of implementing the agreement between you and us.

In addition, we will process your data to comply with statutory obligations or to respond to questions from competent law enforcement agencies, public bodies, courts or authorised data protection authorities.

We process personal data for marketing purposes. We provide you information about our services that we think could be of interest to you. This may include job vacancies, candidates’ resumes, test results, training courses and events. The legal basis for such processing is either Freestone's legitimate interest to inform existing contacts about services offered by Freestone and which are similar to the services it offered earlier to the data subject, or the explicit consent from the data subject.

If Freestone uses your personal data in view of direct marketing efforts, you can oppose such use by simple request at all times (‘opt out’).

If your personal data is processed with your consent, you are entitled to withdraw such consent at all times. To that end, please send a simple request to Freestone, using the contact data mentioned in this privacy statement under ‘Identity of the party responsible for processing the personal data’.

PERSONAL DATA THAT WILL BE PROCESSED

If you wish to use our services, we will process your personal data and ask your consent to do so as and where necessary.

If you visit our website, we collect the following technical data for the purpose of continually monitoring and improving our services as necessary:

• Technical information, such as device type, IP address, browser type, geographic location and operating system
• Information about browsing conduct (time spent on each page, clicking links, which pages are viewed, frequency of visits to a page, etc.)
• Technical details relating to messages and conversations (date, purpose, agreements, actions)

If you fill out a form on the website, subscribe to mailings and/or contact us by phone, email, via suppliers or social media, we may collect the following data:

• Personally identifiable information: name, first name, address, telephone number, email
• Personal characteristics: gender, language choice
• Company data: company, address, telephone number, title, email, invoicing details
• Information regarding the query, contract and/or job vacancy

If you fill out an application form, we may collect the following information:

• Personally identifiable information: name, first name, address, telephone number, email, date of birth
• Personal characteristics: gender, language choice
• Company data: company, address, telephone number, title, email, invoicing details
• Information regarding the query, contract and/or job vacancy
• Resume, cover letter
• Information about education, employers, working experience and knowledge, including any references provided by you

If you seek to use the services of Freestone People in your capacity as an applicant, we will process the following data for the purpose of responding to your queries and needs:

• Personally identifiable information: name, first name, address, telephone number, email, date of birth
• Personal characteristics: gender, language choice
• Company data: company, address, telephone number, title, email, invoicing details
• Information regarding the query, contract and/or job vacancy
• Resume, cover letter
• Information about education, employers, working experience and knowledge
• Notes made during the application process
• Evaluation forms, references, test results and assessment results
• Pay slips and social security documents
• Education
• Payroll information: leave days, marital state, children, deductions
• Any other personal data provided by you.

HOW LONG DOES FREESTONE KEEP YOUR PERSONAL DATA

Freestone does not store your personal data any longer than is strictly necessary for realising the purposes for which the data was gathered, unless a longer storage period is required or justified to ensure compliance with (i) a statutory time limit or due date or (ii) any other statutory requirement.

FORWARDING PERSONAL DATA TO THIRD PARTIES

Freestone only provides your personal data to third parties if any of the following applies:

• If it is necessary for the performance of an agreement with you.
• If you have given your explicit consent to it in writing. You have the right to withdraw your consent at any time. Such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
• If Freestone is required to do so by virtue of a statutory requirement or legal proceedings to safeguard its rights of defence.
• If Freestone transfers all or part of its assets to a third party; in case of transfer of all or part of the company; in case of a merger, division or equivalent action, a joint venture, reorganisation or any other transfer, transition or corporate restructuring, under particular or universal title, in which case your personal data may be transferred to a third party;
• If deemed necessary for realising the purposes described above. We use a third party for:

1. providing our internet environment (web hosting)
2. providing the IT infrastructure (IT network, etc.)
3. organising (and distributing) newsletters and invitations
4. publishing job vacancies on our behalf and conducting personality tests and assessments.

In any case we work with reliable third parties with whom we have entered into a processing agreement if they are data processors, and who will process your personal data only on our behalf in accordance with the purposes defined by us under this privacy statement. Evidently, we make the necessary arrangements with these parties (data processors) to ensure that your personal data is secure. We guarantee that all the data processors with whom we entered into an agreement have an obligation to safeguard the security and integrity of your personal data.

Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose residence or registered office is located in a country that does not fall under an adequacy decision issued by the European Commission, will be governed by rules of a transfer agreement that (i) will contain standard contractual clauses as defined in the ‘Decision of the European Commission of 5 February 2010 (Decision 2010/87/EC); or (ii) is based on any other mechanism by virtue of privacy legislation or any other regulations concerning the processing of personal data.

GOOGLE ANALYTICS

Freestone uses Google Analytics to monitor how the website is used and how effective Freestone’s AdWords ads are in the Google search results.

Together with your computer’s IP address the information thus obtained is transferred to and stored by Google on servers located in the United States. For more information, please read Google’s privacy policy (including the provisions concerning Google Analytics). Google uses this information to monitor how our website is used, to provide reports about the website to Freestone and to be able to offer its advertisers information about the effectiveness of their campaigns. Google may provide this information to third parties if it is legally obliged to do so or insofar as these third parties process information on behalf of Google. This is beyond Freestone’s control. Freestone did not permit Google to use Analytics information obtained through Freestone for other Google services.

RIGHTS OF THE DATA SUBJECT

As a data subject, you can exercise certain rights vis-à-vis Freestone. If you wish to exercise any of those rights, please contact us using the contact details provided in this privacy statement under ‘Identity of the party responsible for processing the personal data’.

You have the following rights:

• Right of access, no later than one month after receipt of the request: you are entitled to access the data we possess to check for which purposes it is used by Freestone.
• Right to modification or rectification of inaccurate data: you may demand that inaccurate or incomplete data is rectified or completed, respectively.
• Right to object if you disagree with the way Freestone is processing your personal data.
• Right to data portability: under certain circumstances you are entitled to receive your personal data in a structured, commonly used and machine-readable format and to transmit that data to third parties.
• Right to erasure: under certain circumstances you have the right to have your personal data erased. This request may be refused in a reasoned decision.
• Right to restriction of processing.

In principle these rights may be exercised free of charge. To do so, you need to send us a request including a copy of your ID-card so as to prevent any unauthorised disclosure of your personal data. Freestone will respond to your request as soon as possible, but no later than within a month following your request.

PROTECTION OF PERSONAL DATA

Freestone takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification.

We have taken appropriate technical and organisational measures to protect your personal data against unlawful processing, for instance:

• Each individual who may acquire knowledge of your personal data on behalf of Freestone has an obligation to observe secrecy in relation to that data.
• We use a policy of username and password on all of our systems.
• We anonymise and encrypt personal data as necessary.
• We back up the personal data so that it can be restored in case of physical or technical incidents.
• We regularly test and evaluate the measures taken.
• Our employees are informed about the importance of personal data protection.
• Freestone’s website uses a reliable SSL Certificate to ensure that your personal data does not fall into the wrong hands.

MINORS (CHILDREN UNDER 13)

Freestone never knowingly processes personal data of minors without the consent of a parent or guardian. If processing, in good faith, of personal data of minors has taken place nonetheless, Freestone will delete this data as soon as possible after becoming aware thereof.

COMPLAINTS

If you have any complaints about the processing of your personal data, we ask that you contact us directly. Should you feel that your data is not properly protected or that there are indications of misuse, or if you wish additional information on the protection of personal data collected by Freestone, please contact Freestone using the contact details provided under ‘Identity of the party responsible for the processing of personal data’. Freestone will make the necessary efforts to provide a response.

In addition, you always have the right to file a complaint with the data protection authority,

Data Protection Authority
35 rue de la Presse
1000 Brussels
Ph.: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
E-mail: contact@apd-gba.be
www.dataprotectionauthority.be

STAY INFORMED ABOUT CHANGES

Freestone may update this privacy statement from time to time, for instance following market developments, new processing activities or reactions of data subjects. For this reason we invite you to regularly check our website for the most recent version of this policy. We will Inform you of any fundamental changes through our website or other common communication channels and, if so required by law, we will ask your prior consent for any intended (new) processing activities.